Digital Product Passport for textiles and apparel
Textiles are the highest-profile ESPR product group and the one most merchants ask about. They are also the group where something is already legally binding — just not the passport.
Short answer. The textile passport itself is not yet law. The delegated act that will define it is indicatively scheduled for 2027, with compliance typically following around eighteen months later. But the ESPR ban on destroying unsold apparel, clothing accessories and footwear took effect on 19 July 2026 for large enterprises — that one is in force now, and it catches clothing retailers who have no passport obligation at all yet.
What is in scope
The ESPR working plan names textiles, in particular garments and footwear, as a priority product group. In practice the Commission has split these: textiles and apparel are proceeding, while footwear has been separated out for its own study.
Preparatory work for the textile delegated act has begun — textiles and steel are the only two groups where the Commission has confirmed work is under way. That makes textiles the most likely group to produce the first real ESPR passport, but "under way" is not the same as "drafted", and the scope boundaries are not yet fixed.
What is likely in scope, and what is genuinely unclear
Garments and household textiles are the obvious core. The boundaries that are not yet settled and that merchants should not guess at:
- Whether accessories such as bags and belts are treated as textiles, as leather goods, or separately.
- How second-hand and vintage clothing is handled — a genuinely difficult question, since the passport concept assumes an identifiable manufacturer.
- Where made-to-order and small-batch production sits, given that passport infrastructure assumes repeatable models.
- Whether technical and industrial textiles come in with apparel or later.
Be sceptical of anyone selling you a "compliant textile DPP" today. No product-specific ESPR delegated act has been adopted for any product group. Until the textile act exists, nobody — no consultant, no vendor, no software product — can tell you what fields a textile passport must carry. What they can sell you is a reasonable anticipation, and that has real value for data collection. It is not compliance, and it should not be priced as such.
Timeline for Textiles & apparel
- 18 July 2024 ESPR enters into force, creating the framework.
- 16 April 2025 First working plan names textiles and apparel as a priority group, with an indicative delegated act in 2027. Footwear is separated out for its own study, due to be completed by the end of 2027.
- 19 July 2026 The destruction ban on unsold apparel, clothing accessories and footwear takes effect for large enterprises, together with the annual disclosure duty. Micro and small enterprises are exempt.
- 2 March 2027 The standardised disclosure template for unsold consumer goods applies — 50+ categories, commodity codes, and statements from waste treatment operators.
- During 2027 Textile delegated act indicatively scheduled. This is the act that will define what a textile passport actually contains. Indicative, not binding.
- ~2028–2029 Realistic earliest compliance window, if the act lands on schedule and follows the usual pattern of roughly eighteen months between adoption and application. Treat as an estimate.
- 19 July 2030 The unsold-goods ban and disclosure duty extend to medium-sized enterprises.
Data the passport has to carry
The textile-specific field list does not exist yet. What follows is the ESPR framework's own Annex III data elements — which every passport must carry regardless of product group — plus the Annex I parameters that a textile act is most likely to draw on, given the Commission's stated priorities for the sector.
Treat the second half as informed anticipation for data-collection planning, not as a specification. The first half is fixed by the framework and is safe to build against.
| Field | What it means in practice | Status |
|---|---|---|
| Unique product identifier | Persistent, connected to a data carrier on the product, its packaging or accompanying documentation. Framework requirement under Article 10. | In force |
| Unique operator identifiers | For the manufacturer, other operators in the chain, and the EU-established responsible operator. Plus unique facility identifiers. | In force |
| Importer details & EORI | Where an importer places the product on the market. Annex III requirement. | In force |
| Commodity codes | TARIC or equivalent, used for the customs verification step. | In force |
| Compliance documentation | Declaration of conformity, technical documentation and conformity certificates as applicable. | In force |
| Substances of concern | Name or code, location within the product, concentration or range, safe-use instructions, and end-of-life handling information. Framework-level under Article 7(5); the specific substance list for textiles comes with the act. | Expected |
| Fibre composition & materials | Expected to build on existing textile labelling requirements. Note the Textile Labelling Regulation revision is currently blocked, which complicates the alignment. | Expected |
| Recycled content | Share of recycled material. Expect this to require documentary evidence rather than a supplier's assertion. | Expected |
| Durability & care | Expected to cover dimensional stability, colour fastness, pilling resistance and washing performance against defined test methods. | Expected |
| Repairability | The horizontal repairability requirement, including a scoring method, is indicatively scheduled for 2027 alongside textiles. | Expected |
| Recyclability | Design for recycling — fibre blends, trims and coatings that impede recycling are the obvious targets. | Expected |
| Environmental footprint | Likely to follow a defined methodology rather than allowing self-declared figures, as it does for batteries. | Expected |
What this means if you sell clothing on PrestaShop
The obligation that is already live
If you are a large enterprise selling apparel, clothing accessories or footwear, you have been subject to the destruction ban since 19 July 2026 — two days before this page was last reviewed. Micro and small enterprises are out of scope entirely, and medium-sized enterprises have until 19 July 2030.
Two duties come with it. You may not destroy unsold stock in those categories, subject to ten specific derogations. And you must publish annually, on an easily accessible page of your own website, the quantity and weight discarded, the reasons, the proportions sent to reuse, recycling, recovery and disposal, and the prevention measures you have taken.
One derogation is worth knowing in detail because it is the one most likely to apply: stock that was not accepted for donation, where "not accepted" means you offered it to at least three suitable social-economy entities in the EU, or offered it via your own website for at least eight weeks. Records must be kept for five years from the disclosure date.
The passport obligation that is not yet live
Nothing about a textile passport binds you today. The useful work is data collection, because the field list will draw on information that currently does not exist in most supply chains — verified recycled content, substance declarations at product level, and footprint figures calculated to a defined method.
If you sell own-brand clothing manufactured outside the EU, you will be treated as the manufacturer when the act lands, and the whole passport will be yours to produce. That is the case worth preparing for now.
And one that arrives in September
From 27 September 2026, Directive (EU) 2024/825 bans generic environmental claims and offsetting-based carbon-neutrality claims. For a clothing store this is likely to bite sooner and harder than the passport: "eco-friendly", "conscious" and "climate neutral" product copy all come under pressure, and unlike the DPP it applies to your existing catalogue on a fixed date.
How to prepare now
Deal with the disclosure duty first, if it applies to you
It is in force, it requires a public page on your own website, and the standardised template arrives on 2 March 2027. Working out your discard volumes and treatment routes takes longer than people expect, particularly if returns are processed by a third party whose reporting does not break down by disposal route.
Start fibre and substance data collection
Fibre composition you probably hold, though as label text rather than structured data. Substance declarations at the level ESPR contemplates — name, location in the product, concentration — almost certainly not. That request has a long lead time through a garment supply chain with multiple tiers, and the mills that know the answer are usually two steps removed from your supplier.
Fix your product identifiers before the act lands
Whatever the textile passport requires, it will be keyed on a persistent unique product identifier. If your catalogue currently identifies products by an internal SKU that changes when a style is re-run, that is worth fixing now — it is independent of the act's content, and it is the part that is expensive to retrofit.
Audit your sustainability copy against the September deadline
This is a smaller job with a firm date. Every generic green claim in your catalogue needs either substantiation or removal before 27 September 2026.
Questions
When exactly do I need a textile passport?
Does the destruction ban apply to my returns?
We are a small online clothing shop. Does any of this apply?
What about second-hand clothing?
Will the textile passport replace the care label?
Sources
Other product groups
Batteries
The only product group with a binding passport date already set. LMT, EV and industrial batteries above 2 kWh, from 18 February 2027.
Tyres
A priority group with an indicative 2027 act, and one that already carries mandatory EU labelling.
Electronics & appliances
Not one group but many. Electronics come in through energy-related products and horizontal rules, on a schedule running from 2026 to 2030.
Get the data before you need the passport
Whatever your product group, the bottleneck is the same: supplier data you do not have yet. The readiness checklist tells you what to start asking for.